IR 05000454/1985035

Safety Insp Rept 50-454/85-35 on 850805-1002.No Violation or Deviation Noted.Major Areas Inspected:Previous Insp Findings & Startup Test Results Evaluation

ML20138B910
Person / Time
Site:	Byron
Issue date:	10/10/1985
From:	Ring M, Vandenburgh C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138B894	List: IR 05000454/1985035 ML20138B890
References
50-454-85-35, NUDOCS 8510220077
Download: ML20138B910 (7)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

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Report No. 50-454/85035(DRS)

Docket No. 50-454 License No. NPF-37 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Unit 1 Inspection at: Byron Station, Byron, IL Inspection Conducted: August 5-8, September 10-13, 17-19 and October 1 , 1985

Inspector: .Chris A. VanDenburgh I

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.h Date b k -- __ g Approved By: M. A. Ring, Chief '*/'offF Test Programs Section Date Inspect on Summary:

Inspection on August 5 through October '2, 1985 (Report No. 50-454/85035(DRS))

Areas Inspected: Routine, announced safety inspection of licensee action on previous inspection findings and startup test results evaluatio The inspection consisted of 87 inspector-hours onsit Results: No violations of deviation were identifie DR ADOCK O 85py g 4.'

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DETAILS Persons Contacted

• R. Pleniewicz, Production Superintendent

• R. Ward, Services Superintendent

• L. Sues, Assistant Superintendent, Operations G. Klopp, Project Engineering Manager P. Donovan, Project Engineering

• J. Langen, Compliance Staff

• A. Chernick, Compliance Supervisor

• F. Hornbeak, Technical Staff Supervisor '

• P. Riester, Technical Staff R. Choinard, Technical Staff L. Wehner, Technical Staff G. Stauffer, Technical Staff T. Melloch, Technical Staff

• R. Gruber, Quality Assurance

• D. St. Clair, Operating Engineer S. Sober, Health Physicist, Radiation Chemistry B. Scott, Health Physicist, Radiation Chemistry

• Denotes those personnel present at the exit interview of October'2, 1985~. Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (454/83047-06(DRS)): This item concerned the' integrated testing of the Control Room (VC), Auxiliary Building (VA), Miscellaneous Electric Equipment Room (VE), and Essential Service Features Switchgear Room (VX) ventilation systems-in all modes of operation to ensure that the control room envelope can be maintained at a positive differential pressure with respect to the adjacent areas.~ This testing'was performed in_ Retest R-284 and approved by the Project Engineering Department (PED) on June 17, 1985. This item was closed in Inspection Report 50/454-85024, Paragraph (0 pen) Open Item (454/85008-02(DRS)): This item concerned the results of RC 63.32, " Reactor Coolant Flow Coastdown." The. licensee based-the approval of this test on an analysis provided by Westinghouse which showed that the value of Tau was 12.40. Westinghouse determined in letter CAW-8456 that a value of Tau greater than 11.87~would show

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that the flow coastdown was acceptable. The licensee has discussed the method of data analysis with the inspector and the' inspector has

no further questions in this area. However, this' item is open because

'the results of RC 63.32 do not document the methodology in which the test data obtained.in RC'63.-32 was calculated and evaluated so as to. ensure that the test requirements have been satisfied. For example, the relative core flows utilized by Westinghouse in their evaluation were not compensated for measurement ~ time delay nor averaged in the same manner-as the values derived in RC 63.32. .The e

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t licensee had not provided this additional information to the test package during this inspection period, however an Action Item Record (AIR) 6-85-357 was initiated to follow this item. Therefore, this

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item will remain ope l (Closed) Violation (454/85008-04(DRS)): This item concerned four separate examples of inadequate documentation of results  !

evaluations. In letters dated August 1 and June 10, 1985, the licensee identified the corrective actions taken to prevent-further '

noncompliance. These actions include the completion of a Westinghouse reanalysis of rod worths, a clarification of startup test NR 32.33 and corresponding FSAR Table 14.2-78 acceptance criteria, a revision to the Byron Startup Manual to require a ,

specific documented resolution of data that does not meet acceptance ;

criteria when approving test results, and the issuance of a Technical *

t Staff Supervisor's Memo to require the documentation of deviations from example calculations or data reduction techniques in the test results evaluation. These items have been reviewed and are considered acceptabl , (Closed) Open Item (454/85024-01(DRS)): This item concerned ,

startup test NR 52.36A, " Axial Flux Difference Calibration,"

performed in the 50, 75, and 100% power level test sequence ,

The approval of the 50 and 75% power level test performances  ;

were conditional to the satisfactory performance of the 100% power :

level test and the satisfactory verification of the incore program results. As discussed in Paragraph 3 of this report, the results of NR 52.36A have been approved and the'results of CX 20.35, " Process ;

Computer Verification and Flux Mapping," have been reviewed by PED

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and accepted by the Statio (Closed) Open Item (454/85024-02(DRS)): This item concerned the

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verification of the process computer with respect to the strip chart :

data taken from the incore detectors. This item is discussed in Paragraph 3 of this report as part of the results evaluation of CX 20.35, " Process Computer Verification and Flux Mapping." l

'i (Closed) Open Item (454/85024-03(DRS)): This-item concerned the i results of FW 34.31, " Calibration of Steam and Feedwater Flow"  :

performed in the 90% power level test sequence. . This item was open >

pending verification that.the additional test data required by PED i i in the 90% power level test sequence was included in the test

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package and-the satis ~ factory performance and evaluation of the 100% !

test procedure. The additional. test data has been added to the test !

j file by the station. The results of the 100% power level i performance of FW 34.31 is discussed in Paragraph 3 of this repor No violations or deviations were' identifie f

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3. Startup Test Results Evaluation The inspector reviewed the following startup test procedures and verified that the results were reviewed against approved acceptance criteria and an evaluation of the test results has been performed in accordance with Regulatory Guide 1.68 and the licensee's Startup Manual:

100% Power Level Test Sequence CV 18.30, " Degassing the Reactor Coolant System" CX 20.35, " Process Computer Verification" EM 28.30C, " Pipe Vibration" FW 34.300, " Steam Generator Water Level Response" FW 34.31, " Calibration of Steam and Feedwater Flow" IT 47.328, E, " Thermal Power Measurement" NR 52.35D, E, F, " Operational Alignment of Excore Nuclear Instruments" NR 52.36B, " Axial Flux Difference Calibration" NR 52.37, " Load Swings" NR 52.38, " Full Power Plant Trip" PS 61.33, " Radiation Surveys during Power Ascension" RC 63.31B, " Reactor Coolant System Flow Measurement" VA 84.30, " Heat Capacity Verification for Auxiliary Building HVAC" LM 133.30B, " Loose Parts Monitor" With respect to the results evaluation of CX 20.35, the inspector notes that PED has reviewed the results of this test and in letters dated July 1 and September 12, 1985, indicated that the results are satisfactory to the station and that therefore no action is required to restrict plant operation because of the results obtained. The licensee has indicated in discussions and in these letters that this test should be more appropriately addressed as a Component Demonstration as opposed to a Startup Test. Since the FSAR does not require the performance of this test and since both the Station and PED have satisfactorily reviewed the results of this test, this method is considered acceptable, With respect to the results evaluation of FW 34.300, the inspector questioned a statement in the STE's test evaluation which indicated that;various controller gains and resets were~ adjusted following the

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satisfactory performance of this procedure. Such adjustments have the potential for invalidating the test result The licensee stated in discussions that the setpoints were modified following the performance of this procedure in an attempt to troubleshoot continuing problems with the Steam Generator Level Control System; however, the controller gains were reset to the original values used during the performance of FW 34.30D following the completion of this troubleshooting. The inspector has no further concerns in this are With respect to the results evaluation of FW 34.31, the inspector noted that the first set of test results were not approved by PED and that further testing was required to be performed. This testing was performed in Special Procedure SPP-85-80. In a letter dated September 16, 1985, PED approved the results of FW 34.31 based on the results of this retestin The licensee has indicated that this

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retest will be retained in the test files for FW 34.3 With respect to the results evaluation of NR 52.350, the inspector questioned the data used in the calculation of the intermediate ,

range and power range nuclear instruments overlap. The test procedure verifies that at least 1 1/2 decades of overlap exist between the two ranges by recording the instruments output at the highest power level at which the intermediate range is still operational and the lowest power level obtained. The values used i for the lowest power level were recorded in Section C2.1.1 of Appendix C in NR 32.33, " Initial Criticality and Low Power Test Sequence," and show 0 microamps and 0% power taken from data sheet 11.8. The expected values for the intermediate range instrument at about 1% power range is expected to be 2-6 microamp Furthermore the test evaluation for Startup Test 52.35F indicates '

that the as found compensa.ing voltage for the intermediate range nuclear instruments was too high. This overcompensation could -

result in the less than expected values for the intermediate range detectors. In their approval letter of August 12, 1985, PED indicated that the values were questionable, but that the required overlap was separately verified. This data could be obtained from an initial conditions data sheet routinely performed for each startup test in the low power test sequence. PED has subsequently provided f this additional information to the test file by memorandum; therefore, '

this item is considered clos 2 . With res'pect to the results evaluation of NR 52.36B, the . inspector ;

noted that deficiency 2C1 was written against section 9.1 for-annunciator alarm 10-804, " Power Range Lower Detector. Flux Deviation !

High," illuminated. The evaluation indicates that the deficiency is ;

closed because the circuitry is not within~the scope of the tes t Further discussions with the licensee have determined that a -

deficiency still exist Nuclear Work Request (NWR) 821688 was !

written following the test to document the same problem and later

.was incorrectly closed to a modification. A new NWR (B22551) was !

again written when the same problem reoccurred. This NWR is still open. This item will be followed as an unresolved item-pending a *

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4 licensee investigation into the circumstances of the deficiency- ,

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and'NWR 822551 (454/85035-01).  ! With respect to the results evaluation of NR 52.38, the inspector

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noted that during the performance of this test two of the main steam safety valves on Steam Generator.C opened in violation of the >

FSAR Acceptance Criteria, because the Power Operated Relief V' alve 1 (PORV) was isolated. In a letter dated September 18, 1985, PED

accepted the' test results based on a determination that the safety  ;

valves acted as substitutes'for the isolated PORV and that, had the

PORV not been isolated, the safety valves would not have lifte i Discussions with the NRR Licensing Project Manager and Reviewer have  ;

determined that this approach is acceptable, , With respect to the results evaluation of PS 61.33, the inspector i

, noted that not all the acceptance. criteria were met in that the  !

neutron dose rates for 19 radiation base points (RBPs) exceeded the acceptance criteria levels. AIR 6-85-277 has been initiated to

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require-retesting of these points following a modification to the  ;

reactor vessel nozzle shield covers. This item will be followed as .'

an open item pending-the completion of this additional testing I (454/85035-02). , With respect to the results evaluation of RC 63.318, the inspector  ;

noted that the barometric pressure assumed in the data evaluation .

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was different frcm that recorded in data sheet 11.1.1c of Startup ,

Test ~IT 47.32E, which was performed at the same time as RC 63.31 ;

Based on this observation the licensee has reviewed the performances i

of RC 63.31B in the 30, 50, 75, and 100% power -level test sequences l and determined that the~ absolute pressure value used in the data  ;

reduction did not coincide with the pressure recorded in IT 47.3 i The licensee has also verified, however, that the different values for barometric pressure had no effect on the previously accepted l results of RC 63.318. .This investigation has been documented by

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a memo to file. The inspector has no further concerns in this are ;

I No violations or deviations were identified; however,! wo t areas require i further review and are-documented as an open and an unresolved ite ,

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4. Open Items f

l Open items are matters which have been discussed with the licensee, which {

will be reviewed further by the inspector, and which involve some action i on the part of the NRC or licensee or both. An open item disclosed  ;

o during the inspection is discussed in Paragraph j

5. Unresolved Items f

Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations,'o !

} deviations. =An unresolved item: disclosed during the inspection is '

i discussed in Paragraph- .

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6. Exit interview The inspector met with licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on October 2, 1985. The inspector summarized the purpose and scope of the inspection and the finding The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietar